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LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
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EXHIBIT “45”
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 1 of 29 Page ID#:4860
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Exhibit "54"
Pg. 404
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 2 of 29 Page ID#:4861
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
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Exhibit "45"
Pg. 405
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Exhibit "45"
Pg. 406
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 4 of 29 Page ID#:4863
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Exhibit "45"
Pg. 407
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8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
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UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
LISA LIBERI §
And §PHILIP J. BERG, ESQUIRE § CIVIL ACTION NO. 09-1898
And §
THE LAW OFFICES OF PHILIP J. BERG §AndEVELYN ADAMS a/k/a MOMMA
E and
LISA M. OSTELLA
§
§
§
§And
GO EXCEL GLOBAL,§
§
§
Assigned to Honorable Eduardo C.
Robreno
Plaintiffs §
§§
Vs. §§
§
ORLY TAITZ, a/k/a DR. ORLY TAITZ, §a/k/a LAW OFFICES OF ORLY TAITZ, §
a/k/a WWW.ORLY TAITZESQ.COM a/k/a §
WWW.REPUBX.COM a/k/a ORLY TAITZ §And §
LINDA SUE BELCHER a/k/a LINDA S. §
BELCHER a/k/a LINDA STARR a/k/a § NEWWOMENSPARTY a/k/a §
STITCHENWITCH a/k/a EVA BRAUN §
a/k/a WEB SERGEANT a/k/a KATY a/k/a §
WWW.OBAMACITIZENSHIPDEBATE.ORG §And §
EDGAR HALE a/k/a JD SMITH, §
And §CAREN HALE, §
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com
Exhibit "45"
Pg. 408
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 6 of 29 Page ID#:4865
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
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And §PLAINS RADIO NETWORK, §
a/k/a PLAINS RADIO NETWORK, §
INC. a/k/a §PLAINS RADIO, §
And §
BAR H FARMS; §And §
KPRN AM 1610; §
And §
DOES 1 through 200 Inclusive §§
Defendants §
ANSWER
Defendants deny all allegations of wrong doing contained in the complaint.
Dated:
____________________
Dr. Orly Taitz, ESQ
26302 La Paz ste 211Mission Viejo, CA 92691
Pro se and as the President of Defend our Freedoms Foundation on behalf of Defend Our Freedoms
Foundation.
Certificate of Delivery
I, Orly Taitz, certify that a true and correct copy of the foregoing was mailed to Philip Berg on this 22
day of May, 2009 via Overnight Federal Express and via ForSure Legal Services Service of Process, 250Woodlake Dr. Holland PA 18966
_____________________ Orly Taitz
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
LISA LIBERI §
And §PHILIP J. BERG, ESQUIRE § CIVIL ACTION NO. 09-1898
And §
THE LAW OFFICES OF PHILIP J. BERG §
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com
Exhibit "45"
Pg. 409
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 7 of 29 Page ID#:4866
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
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AndEVELYN ADAMS a/k/a MOMMA
E and
LISA M. OSTELLA
§
§
§
§And
GO EXCEL GLOBAL,§
§
§
Assigned to Honorable Eduardo C.
Robreno
Plaintiffs §§
§
Vs. §§
§
ORLY TAITZ, a/k/a DR. ORLY TAITZ, §a/k/a LAW OFFICES OF ORLY TAITZ, §
a/k/a WWW.ORLY TAITZESQ.COM a/k/a §
WWW.REPUBX.COM a/k/a ORLY TAITZ §And §
LINDA SUE BELCHER a/k/a LINDA S. §BELCHER a/k/a LINDA STARR a/k/a §
NEWWOMENSPARTY a/k/a §STITCHENWITCH a/k/a EVA BRAUN §
a/k/a WEB SERGEANT a/k/a KATY a/k/a §
WWW.OBAMACITIZENSHIPDEBATE.ORG §And §
EDGAR HALE a/k/a JD SMITH, §
And §CAREN HALE, §
And §
PLAINS RADIO NETWORK, §a/k/a PLAINS RADIO NETWORK, §INC. a/k/a §
PLAINS RADIO, §
And §BAR H FARMS; §
And §
KPRN AM 1610; §And §
DOES 1 through 200 Inclusive §
§
Defendants §
Motion to Dismiss Due to Lack of Jurisdiction
Here come the defendants Orly Taitz, pro se and Orly Taitz, President of Defend Our Freedoms
Foundation on behalf of Defend Our Freedoms Foundation and allege the following:
| Dr. Orly Taitz Esquire http://www.orlytaitzesq.com
Exhibit "45"
Pg. 410
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 8 of 29 Page ID#:4867
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
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1. Current action has no nexus to the State of Pennsylvania and no subject matter jurisdiction.
The defendants do not reside within this jurisdiction within the meaning of 28 U.S.C.A. §
1391 (b) and the claim for which this action arose is outside of this
jurisdictional district. No federal question is alleged in the
complaint. Notwithstanding the above, the defendants deny every
allegation of the Plaintiff’s claim.
2. Above legal action stems from fraudulent use of name and Good Will of Defend Our Freedoms
foundation by web master Lisa Ostella, (hereinafter Ostella) plaintiff in this action, resident of
New Jersey and financial benefit drawn by other plaintiffs in this action as a result of Ostella’s
activities.
3. Defend Our Freedoms foundation is registered in the state of California by Orly Taitz, ESQ
(Taitz, hereinafter), president of the foundation, resident of the state of California as well.
Initial registration form, State of California, Office of the Attorney General, Registry of
Charitable Trusts submitted on December 17, 2008, Recorded in Orange County, California
12.23.08
4.
Orly Taitz never went by the name www.repubx.com and it is not an a/k/a of Orly Taitz.
Repubx.com is a web site/blog, owned by another party, with no relation to this action.
5. www.orlytaitzesq.com is not a legal entity and not an a/k/a for Orly Taitz.
www.orlytaitzesq.com is a name of a blog/website run by Orly Taitz.
6. Orly Taitz, inc is not an a/k/a for Orly Taitz. It is a name of a dental practice in California,
incorporated and separate legal entity, with no relation to current dispute.
7.
Law offices of Orly Taitz are not an a/k/a for Orly Taitz. It is a name of a law office with no
relation to the dispute.
8. Plaintiff Lisa Liberi (hereinafter Liberi) is a Resident of the State of New Mexico. Plaintiff’s
attorney Philip Berg (Hereinafter Berg) has listed Liberi‘s address to be an address of his office
in Pennsylvania, however Liberi does not reside in the state of Pennsylvania nor physically
| Dr. Orly Taitz Esquire http://www.orlytaitzesq.com
Exhibit "45"
Pg. 411
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 9 of 29 Page ID#:4868
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
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work in Berg’s office in the state of Pennsylvania. Liberi is an assistant, who has some legal
background related to her own criminal convictions and who assists Berg occasionally via e-
mails, phone and mail sent from her residence in New Mexico. Berg has improperly asserted
her residence in Pennsylvania, due to the fact that this is a state where he is licensed to
practice law, in order to try to obfuscate her real residence in New Mexico and improperly
bring a legal action in the state of Pennsylvania. Liberi claims that she was defamed by Orly
Taitz, disclosing to the public, Court printout of Liberi’s convictions of forgery and grand theft.
Taitz denies all allegations and assets that all of the information provided was truthful and
convictions in question were in the state of California, (addendum 1 Printout of Liberi
convictions in San Bernardino county, California) Liberi’s prosecuting district Attorney James
Secord is in San Bernardino County, California; arresting officer and all of the detectives are in
the state of California, numerous victims of her criminal activity and potential witnesses in this
action are in the state of California, therefore a proper jurisdiction for this action and
forthcoming counter complaint is in the state of California.
9. Liberi got an eight year term in January 2008 in California, she is currently on probation and
would be extradited back to California to serve her term, if she indeed violated the conditions
of her probation.
10. When Ostella fraudulently represented herself as Defend Our Freedoms foundation and
solicited donations for the Defend Our Freedoms Foundation, Taitz has written a cease and
desist letter to Ostella, Berg and Adams, who were benefiting from Ostella’s activities.
11. When the above activity did not cease and desist, Taitz has filed a police report, describing
donations fraudulently misdirected from Defend our freedoms foundation. The report 09-
068339 was filed in the city of registration of the foundation, Mission Viejo in the state of
California, which would be a proper jurisdiction in this action. (Addendum 2- Orange County,
California Recording for Defend Our Freedoms Foundation, Addendum 3 Police report 09-
068339)
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com
Exhibit "45"
Pg. 412
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 10 of 29 Page ID#:4869
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
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12. Liberi, had developed a modus operandi of filing malicious and frivolous law suits against
victims of her criminal behavior, law enforcement and judiciary in order to gain some
advantage in her criminal prosecution and in fact she has filed so many frivolous complaints
and legal actions against the District Attorney, District Attorney’s office, Presiding Judge, police
officers, detectives, her own defense attorneys, San Bernardino County in California and even
hospital, where she was treated, that as a condition of her probation, she is obligated to
properly clear with her probation department any legal action she is planning to file. If Liberi
did not fulfill her obligation, probation will be revoked and she will be extradited from New
Mexico to California to serve her eight year prison term, which makes California a proper
Jurisdiction. (addendum 1 )
13. Most of victims of Liberi’s malicious and frivolous law suits reside in the state of California,
which would be a proper jurisdiction.
14. Liberi has gotten a reduction of her prison term to probation due to her claim of being sick
and disabled. Taitz has called District Attorney of San Bernardino County James Secord and
verified, that Liberi is on disability and receiving disability payments from Social Security
Administration. In current case Berg states that Liberi is employed at his office. If indeed Berg
is paying or was paying Liberi a salary or any other payment directly or indirectly through her
husband Brent Liberi, while Liberi was receiving social security payments for disability, that
would constitute Social Security fraud, violation of her probation and would be grounds for her
extradition to California to serve her eight year prison term, which makes the state of
California a proper Jurisdiction.
15.
Due to the fact, that Liberi was convicted of economic crimes and forgery of documents, as a
condition of her probation, she is not allowed to have any access to credit cards belonging to
others or bank accounts belonging to others. Berg’s office was handling a large donations
drive. If indeed Liberi directly or indirectly was handling credit cards or credit card accounts of
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com
Exhibit "45"
Pg. 413
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 11 of 29 Page ID#:4870
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
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others, she will be in violation of her probation and will be extradited to California, a proper
jurisdiction in this case.
16. Due to the above, Berg, an attorney for Ostella, Liberi and Adams being concerned that upon
completion of the police investigation in California, Taitz will file a legal action against his
clients and him personally, improperly filed a legal action in Pennsylvania with no nexus to the
dispute at hand, with the sole purpose of harassing and intimidating Taitz and other
defendants and trying to denigrate Taitz in anticipation of trial.
Due to the above defendants respectfully request dismissal of the current action in the state of
Pennsylvania due to lack of subject matter jurisdiction and personal jurisdiction. Venue was improperly
under 28 U.S.C.A. §1391 (b)
Wherefore, defendants demand judgment that the complaint be dismissed, together with the costs
and disbursements of this action.
Dated 05.21.09.
Dr. Orly Taitz ESQ
26302 La Paz, ste 211
Mission Viejo, CA 92691
Pro Se and on behalf of Defend our Freedoms Foundation and as a president of Defend Our Freedoms
Foundation
Addendum 1 Case FWV028000 – Defendants
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com
Exhibit "45"
Pg. 414
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 12 of 29 Page ID#:4871
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
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to lack of subject ma er jurisdic on and personal jurisdic on. Venue was improperly under 28 U.S.C.A.§1391 (b)
Wherefore, defendants demand judgment that the complaint be dismissed, together with the costs and
disbursements of this ac on.
Dated 05.21.09.
Dr. Orly Taitz ESQ
26302 La Paz, ste 211
Mission Viejo, CA 92691
Pro Se and on behalf of Defend our Freedoms Founda on and as a president of Defend Our Freedoms
Founda on
Addendum 1 Case FWV028000 – Defendants
Seq Defendant Next Court Date Status Agency / DR Number
Arrest Date Count 1 Charge Violation Date
1 LIBERI , LISA R RA110013759
05/18/2001 PC 115(A) 05/18/2001
ALIAS: LIBERI, LISA R
ALIAS: COURVILLERICHARDSON, LISA
ALIAS: LIBERI, LISA A
ALIAS: RICHARDSON, LISA C
ALIAS: COURVILLERICH, LISA
ALIAS: LIBERI, LISA RENEE
ALIAS: LIBERI, LISA
ALIAS: RICHARDSON, LISA RENEE
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Status
Custody N/A
Filing Type Held to Answer Filing Date 05/09/2003
Ordered Bail $0.00 Posted Bail $0.00
D.A. James R. Secord Defense Dean Pitcl (Court Appointed)
Next Action: Deputy Report #: RA-RC 110013759
Warrant Type Status Issued Affidavit Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Charges
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com
Exhibit "45"
Pg. 415
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Arrest Charges
Count Charge Severity Description ViolationDate
Plea Status
1 PC 459 F BURGLARY 05/18/2001
Filed Charges
Count Charge Severity Description ViolationDate
Plea Status
1 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
2 PC 470(D) F FORGERY 05/18/2001 HTA
3 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 HTA
4 PC 115(A) F OFFER/ETC FALSE/FORGED INSTRUMENT TOFILE
05/18/2001 HTA
5 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
6 PC 470(D) F FORGERY 05/18/2001 HTA
7 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 HTA
8 PC 115(A) F OFFER/ETC FALSE/FORGED INSTRUMENT TOFILE
05/18/2001 HTA
9 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
10 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
11 PC487(D)(1)
F GRAND THEFT: AUTOMOBILE/ANIMAL/ETC 05/18/2001 HTA
12 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
13 PC487(D)(1)
F GRAND THEFT: AUTOMOBILE/ANIMAL/ETC 05/18/2001 HTA
14 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
15 PC487(D)(1)
F GRAND THEFT: AUTOMOBILE/ANIMAL/ETC 05/18/2001 HTA
16 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
17 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
Infor Charges
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com
Exhibit "45"
Pg. 416
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Count Charge Severity Description ViolationDate
Plea Status
1 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 GUILTY CONVICTED
2 PC 476A(A) F NONSUFFICIENT FUNDS: CHECKS 05/18/2001 GUILTY CONVICTED
3 PC 470(D) F FORGERY 05/18/2001 DISMISSED
4 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 DISMISSED
5 PC 115(A) F OFFER/ETC FALSE/FORGED INSTRUMENT TOFILE
05/18/2001 GUILTY CONVICTED
6 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 GUILTY CONVICTED
7 PC 476 F MAKING, POSSESSING, UTTERING FICTIOUSINSTRS
05/18/2001 DISMISSED
8 PC 470(D) F FORGERY 05/18/2001 DISMISSED
9 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 GUILTY CONVICTED
10 PC 115(A) F OFFER/ETC FALSE/FORGED INSTRUMENT TOFILE
05/18/2001 DISMISSED
11 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 GUILTY CONVICTED
12 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 GUILTY CONVICTED
13 PC
487(D)(1)
F GRAND THEFT: AUTOMOBILE/ANIMAL/ETC 05/18/2001 DISMISSED
14 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 DISMISSED
15 PC487(D)(1)
F GRAND THEFT: AUTOMOBILE/ANIMAL/ETC 05/18/2001 DISMISSED
16 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 DISMISSED
17 PC487(D)(1)
F GRAND THEFT: AUTOMOBILE/ANIMAL/ETC 05/18/2001 DISMISSED
18 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 GUILTY CONVICTED
19 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 GUILTY CONVICTED
20 PC 115(A) F OFFER/ETC FALSE/FORGED INSTRUMENT TOFILE
05/18/2001 GUILTY CONVICTED
21 PC 470(D) F FORGERY 05/18/2001 DISMISSED
22 PC 470(D) F FORGERY 05/18/2001 DISMISSED
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com
Exhibit "45"
Pg. 417
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ALIAS: RICHARDSON, LISA C
ALIAS: COURVILLERICH, LISA
ALIAS: LIBERI, LISA RENEE
ALIAS: LIBERI, LISA
ALIAS: RICHARDSON, LISA RENEE
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Status
Custody N/A
Filing Type Held to Answer Filing Date 05/09/2003
Ordered Bail $0.00 Posted Bail $0.00
D.A. James R. Secord Defense Dean Pitcl (Court Appointed)
Next Action: Deputy Report #: RA-RC 110013759
Warrant Type Status Issued Affidavit
NONE N/A N/A
Probation Type Granted Expiration
Formal 03/21/2008 03/21/2011
Sentence Convicted Date County Jail CTS
01/25/2008 26 Days 26 Days
State Prison Max Sentence
N/A N/A
Fine and Penalty Restitution Fine Restitution to Victim
0 N/A
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Charges
Arrest Charges
Count Charge Severity Description ViolationDate
Plea Status
1 PC 459 F BURGLARY 05/18/2001
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com
Exhibit "45"
Pg. 418
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 16 of 29 Page ID#:4875
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1908-plaintiffs-exhibits-45-47-to-amended-complaint1908 17/29
Filed Charges
Count Charge Severity Description ViolationDate
Plea Status
1 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
2 PC 470(D) F FORGERY 05/18/2001 HTA
3 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 HTA
4 PC 115(A) F OFFER/ETC FALSE/FORGED INSTRUMENT TOFILE
05/18/2001 HTA
5 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
6 PC 470(D) F FORGERY 05/18/2001 HTA
7 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 HTA
8 PC 115(A) F OFFER/ETC FALSE/FORGED INSTRUMENT TOFILE
05/18/2001 HTA
9 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
10 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
11 PC487(D)(1)
F GRAND THEFT: AUTOMOBILE/ANIMAL/ETC 05/18/2001 HTA
12 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
13 PC487(D)(1)
F GRAND THEFT: AUTOMOBILE/ANIMAL/ETC 05/18/2001 HTA
14 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
15 PC487(D)(1)
F GRAND THEFT: AUTOMOBILE/ANIMAL/ETC 05/18/2001 HTA
16 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
17 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 HTA
Infor Charges
Count Charge Severity Description ViolationDate
Plea Status
1 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 GUILTY CONVICTED
2 PC 476A(A) F NONSUFFICIENT FUNDS: CHECKS 05/18/2001 GUILTY CONVICTED
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com
Exhibit "45"
Pg. 419
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 17 of 29 Page ID#:4876
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1908-plaintiffs-exhibits-45-47-to-amended-complaint1908 18/29
3 PC 470(D) F FORGERY 05/18/2001 DISMISSED
4 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 DISMISSED
5 PC 115(A) F OFFER/ETC FALSE/FORGED INSTRUMENT TOFILE
05/18/2001 GUILTY CONVICTED
6 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 GUILTY CONVICTED
7 PC 476 F MAKING, POSSESSING, UTTERING FICTIOUSINSTRS
05/18/2001 DISMISSED
8 PC 470(D) F FORGERY 05/18/2001 DISMISSED
9 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 GUILTY CONVICTED
10 PC 115(A) F OFFER/ETC FALSE/FORGED INSTRUMENT TOFILE
05/18/2001 DISMISSED
11 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 GUILTY CONVICTED
12 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 GUILTY CONVICTED
13 PC487(D)(1)
F GRAND THEFT: AUTOMOBILE/ANIMAL/ETC 05/18/2001 DISMISSED
14 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 DISMISSED
15 PC487(D)(1)
F GRAND THEFT: AUTOMOBILE/ANIMAL/ETC 05/18/2001 DISMISSED
16 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 DISMISSED
17 PC487(D)(1) F GRAND THEFT: AUTOMOBILE/ANIMAL/ETC 05/18/2001 DISMISSED
18 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 GUILTY CONVICTED
19 PC 487(A) F GRAND THEFT: PROPERTY/ETC OVER $400 05/18/2001 GUILTY CONVICTED
20 PC 115(A) F OFFER/ETC FALSE/FORGED INSTRUMENT TOFILE
05/18/2001 GUILTY CONVICTED
21 PC 470(D) F FORGERY 05/18/2001 DISMISSED
22 PC 470(D) F FORGERY 05/18/2001 DISMISSED
23 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 DISMISSED
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Probation
Probation Type: FORMAL Granted: 03/21/2008 Expire: 03/21/2011
SUPERVISED PROBATION GRANTED FOR A PERIOD OF 36 MONTHS ON FOLLOWING TERMS AND CONDITIONS:
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com
Exhibit "45"
Pg. 420
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 18 of 29 Page ID#:4877
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1908-plaintiffs-exhibits-45-47-to-amended-complaint1908 19/29
1) SERVE 26 DAYS IN A SAN BERNARDINO COUNTY JAIL FACILITY, WITH CREDIT FOR TIME SERVED, AMATTER OF 26 DAYS, PLUS CONDUCT CREDIT PURSUANT TO 1-PC4019 ND ABIDE BY ALL RULES ANDREGULATIONS OF THE FACILITY WITHOUT THE POSSIBILITY OF COUNTY PAROLE.
2) VIOLATE NO LAW.
3) REPORT TO THE PROB OFFICER IN PERSON IMMEDIATELY 0- ND THEREAFTER ONCE EVERYFOURTEEN (14) DAYS OR AS DIRECTED. REPORT TO THE PROB OFFICER IN PERSON IMMEDIATELY 0-ND THEREAFTER ONCE EVERY FOURTEEN (14) DAYS OR AS DIRECTED.
4) COOPERATE WITH THE PROBATION OFFICER IN A PLAN OF REHABILITATION AND FOLLOW ALLREASONABLE DIRECTIVES OF THE PROBATION OFFICER.
5) SEEK AND MAINTAIN GAINFUL EMPLOYMENT, OR ATTEND SCHOOL, AND KEEP THE PROBATIONOFFICER INFORMED OF STATUS OF EMPLOYMENT, OR SCHOOL.
6) KEEP THE PROBATION OFFICER INFORMED OF PLACE OF RESIDENCE AND COHABITANTS AND GIVEWRITTEN NOTICE TO THE PROBATION OFFICER TWENTY-FOUR (24) HOURS PRIOR TO ANY CHANGES.PRIOR TO ANY MOVE PROVIDE WRITTEN AUTHORIZATION TO THE POST OFFICE TO FORWARD MAILTO THE NEW ADDRESS. PERMIT VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGENTS OFTHE PROBATION DEPT. AND/OR LAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCEWITH PERMIT VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THE PROBATIONDEPT. AND/OR LAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCE WITH PERMIT
VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THE PROBATION DEPT. AND/ORLAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCE WITH THE TERMS ANDCONDITIONS OF PROBATION; NOT DO ANYTHING TO INTERFERE WITH THIS REQUIREMENT, ORDETER OFFICERS FROM FULFILLING THIS REQUIREMENT, SUCH AS THE TERMS AND CONDITIONS OFPROBATION; NOT DO ANYTHING TO INTERFERE WITH THIS REQUIREMENT, OR DETER OFFICERSFROM FULFILLING THIS REQUIREMENT, SUCH AS ERECTING ANY LOCKED FENCES/GATES THATWOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE ANY ANIMALS ON THE PREMISES THATWOULD REASONABLY DETER, ERECTING ANY LOCKED FENCES/GATES THAT WOULD DENY ACCESSTO PROBATION OFFICERS, OR HAVE ANY ANIMALS ON THE PREMISES THAT WOULD REASONABLYDETER, THREAT THREATEN THE SAFETY OF, OR INTERFERE WITH, OFFICERS ENFORCING THISTERM. EN THE SAFETY OF, OR INTERFERE WITH, OFFICERS ENFORCING THIS TERM.
7) NEITHER POSSESS NOR HAVE UNDER YOUR CONTROL ANY DANGEROUS OR DEADLY WEAPONS OREXPLOSIVE DEVICES OR MATERIALS TO MAKE EXPLOSIVE DEVICES.
SUBMIT TO A SEARCH AND SEIZURE OF YOUR PERSON, RESIDENCE AND/OR PROPERTY UNDERYOUR CONTROL AT ANY TIME OF THE DAY OR NIGHT BY ANY LAW-ENFORCEMENT OFFICER, WITHOR WITHOUT A SEARCH WARRANT, AND WITH OR WITHOUT CAUSE (PEOPLE -V- BRAVO).
9) NEITHER USE NOR POSSESS ANY CONTROLLED SUBSTANCE WITHOUT MEDICAL PRESCRIPTION. APHYSICIANS’S WRITTEN NOTICE IS TO BE GIVEN TO THE PROBATION OFFICER.
10) SUBMIT TO A CONTROLLED SUBSTANCE TEST AT DIRECTION OF PROBATION OFFICER. EACH TEST ISSUBJECT TO AN $11.00 FEE, TO BE COLLECTED BY CENTRAL COLLECTIONS
11) NOT POSSESS ANY TYPE OF DRUG PARAPHERNALIA, AS DEFINED IN H&S11364.5(D)
12) PARTICIPATE IN A COUNSELING PROGRAM AS DIRECTED BY THE PROBATION OFFICER, SUBMITMONTHLY PROOF OF ATTENDANCE AND/OR SUCCESSFUL COMPLETION TO THE PROBATION OFFICERAS DIRECTED AND BE RESPONSIBLE FOR PAYMENT OF ALL PROGRAM FEE(S).
13) NOT ASSOCIATE WITH KNOWN CONVICTED FELONS OR ANYONE ACTIVELY ENGAGED IN CRIMINALACTIVITY B-OR CODEFENDANT(S) OR VICTIM(S).
14) NOT ASSOCIATE WITH KNOWN ILLEGAL USERS OR SELLERS OF CONTROLLED SUBSTANCES,
15) NOT MAINTAIN A CHECKING ACCOUNT OR COMPLETE OR ENDORSE ANY CHECKS UNLESS MADEPAYABLE TO YOU AND NOT HAVE ANY BLANK CHECKS IN YOUR POSSESSION WITHOUT PERMISSIONOF THE PROBATION OFFICER.
Category: Supporting Documentation, Uncategorized
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com
Exhibit "45"P . 421
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 19 of 29 Page ID#:4878
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1908-plaintiffs-exhibits-45-47-to-amended-complaint1908 20/29
EXHIBIT “46”
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 20 of 29 Page ID#:4879
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1908-plaintiffs-exhibits-45-47-to-amended-complaint1908 21/29
Exhibit "46"
Pg. 422
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 21 of 29 Page ID#:4880
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1908-plaintiffs-exhibits-45-47-to-amended-complaint1908 22/29
VIDEOS
Home
Dr. Orly Taitz Esquire
Defend Our Freedoms Foundation – 29839 Santa Margarita Pkwy, ste 100, RanchoSanta Margarita CA, 92688 – Copyright 2010
World's Leading Obama Eligibility Challenge Web Site
Your donations to the cause are much appreciated.
WHEN THE PEOPLE FEAR THEIR GOVERNMENT,
THERE IS TYRANNY.
WHEN THE GOVERNMENT FEARS THE PEOPLE,
THERE IS LIBERTY.
- Thomas Jefferson
The articles posted represent only the opinion of the writers, do not necessarily represent the opinion of Dr. Taitz, ESQ, and Dr. Taitz, ESQ has no means of
checking the veracity of all the claims and allegations in the articles.
Follow up on Sen, Inhofe and possible visit to Tulsa
OK
Posted on | May 29, 2009 | 6 Comments
I might be going to Tulsa, OK this coming WD, it is not final yet. There is movement in re. to Sen. Inhofe. His
aid Ellen Broun, working in DC office in Hart senate building was put in charge of investigating the issue of
BO’s ineligibility for Sen. Inhofe. Ellen does not want any blog article or e-mails. She wants only documents
and statements and she wants those mailed to her. Please forward to her my dossiers. #6 and #1 are most
important.
Category: Uncategorized
w up on Sen, Inhofe and possible visit to Tulsa OK | Dr. Orly Taitz ... http://www.orlytaitzesq.com
5/1/2011 1
http://www.orlytaitzesq.com/?p=1757
Exhibit "46"
Pg. 423
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 22 of 29 Page ID#:4881
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1908-plaintiffs-exhibits-45-47-to-amended-complaint1908 23/29
Comments
6 Responses to “Follow up on Sen, Inhofe and possible visit to Tulsa OK”
Nick
May 29th, 2009 @ 10:15 pm
Be sure to send her both http://www.wethepeoplefoundation.org/PROJECTS/Obama/Evidence
/AFFIDAVIT-Bishop.pdf and http://www.wethepeoplefoundation.org/PROJECTS/Obama/Evidence/AFFIDAVITexhibit2.pdf
1.
Ron
May 29th, 2009 @ 10:43 pm
Email and/or mailing address please . . .
2.
May 29th, 2009 @ 11:47 pm
contact [email protected] he is organizing the meetings
3.
queenofshina
May 30th, 2009 @ 1:08 am
Senator James M. Inhofe
453 Russell Senate Office Building
Washington, DC 20510
Attention: Ellen Broun
4.
Tia
May 30th, 2009 @ 1:02 pm
Dr Orly, what is her postal address, as you have stated, she didn’t want emails.
5.
May 30th, 2009 @ 1:42 pm
I posted it on the blog yesterday, it is in Russell building
6.
!! IMPORTANT NOTICES – PLEASE READ !!
NEW! CA REP CENTRAL COMMITTEE LISTCAMPAIGN FLIER for Orly Taitz as CA SOS
CAMPAIGN FLIER for Orly Taitz as CA SOS, 2 Per Page
How to contact public Integrity unit
See The PDF File Here
US Department of Justice has a special unit in their Criminal Division called the
PUBLIC INTEGRITY SECTION
w up on Sen, Inhofe and possible visit to Tulsa OK | Dr. Orly Taitz ... http://www.orlytaitzesq.com
5/1/2011 1
Exhibit "46"
Pg. 424
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 23 of 29 Page ID#:4882
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1908-plaintiffs-exhibits-45-47-to-amended-complaint1908 24/29
EXHIBIT “47”
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 24 of 29 Page ID#:4883
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1908-plaintiffs-exhibits-45-47-to-amended-complaint1908 25/29
Exhibit "47"
Pg. 425
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 25 of 29 Page ID#:4884
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1908-plaintiffs-exhibits-45-47-to-amended-complaint1908 26/29
VIDEOS
Home
Dr. Orly Taitz Esquire
Defend Our Freedoms Foundation – 29839 Santa Margarita Pkwy, ste 100, RanchoSanta Margarita CA, 92688 – Copyright 2010
World's Leading Obama Eligibility Challenge Web Site
Your donations to the cause are much appreciated.
WHEN THE PEOPLE FEAR THEIR GOVERNMENT,
THERE IS TYRANNY.
WHEN THE GOVERNMENT FEARS THE PEOPLE,
THERE IS LIBERTY.
- Thomas Jefferson
The articles posted represent only the opinion of the writers, do not necessarily represent the opinion of Dr. Taitz, ESQ, and Dr. Taitz, ESQ has no means of
checking the veracity of all the claims and allegations in the articles.
I am trying to stay away from Liberi-Berg issue,
but i got more questions and here is more info.
Posted on | May 31, 2009 | 7 CommentsI was asked by a number of people to explain why the name of Lisa Ostella is on the dossier #4.
When I was in Washington DC, I did not have an access to the Internet, as I was visiting the Director of the
Selective Service William Chatfield and offices of several senators and was on the phone with the assistant
and legal counsel for Admiral Malin. A lot of people asked me for an update and I called Lisa Ostella, the web
master ,and asked her to post it on the Internet. As you can see, the fact that she signed
DefendOurfFeedomsFoundations, and she put her name as an assistant to me, clearly shows that she knew it
is my foundation, under my name and she could sign as an assistant only as long as she was helping me. The
moment I transferred to another webmaster, she had and has no right to advertise on behalf of the
rying to stay away from Liberi-Berg issue, but i got more questions a... http://www.orlytaitzesq.com
http://www.orlytaitzesq.com/?p=1843
5/1/2011 1
Exhibit "47"
Pg. 426
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 26 of 29 Page ID#:4885
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1908-plaintiffs-exhibits-45-47-to-amended-complaint1908 27/29
DefendOurFreedoms foundation, solicit donations and pocket the money.
You can also see (in the attachment) that she was the one that contacted the private investigator Mr. Sankey,
and provided him the information that Lisa Liberi , assistant to Phil Berg, has a criminal record. Based on
her report Mr. Sankey has investigated and confirmed this information, that indeed Lisa Liberi has this
lengthy record of forgery of documents and forgery of an official seal and grand theft. Lisa Ostella changed
her tune only after this whole issue with pay-pal came out. At first she and the rest of the plaintiffs came out
with an outrageous lie that my husband was spying on people. Now they dismissed their law suit against my
husband- and everybody knows that it was a manufactured charge.
As you can see, she was well aware about Liberi’s criminal record, as was Berg and Liberi herself. Their legal
action is nothing but perjury and an attempted obstruction of justice. I have written in the pleadings that the
only address that Liberi provided, was Berg’s office address and the reason is that she indeed resides in
NM and is the Lisa Liberi with the criminal record. I received an e-mail recently that in the last couple of
days Lisa Liberi has gotten a PA drivers license. If she got one in the last couple of days, that doesn’t change
the fact that she resided in NM and that all of them committed perjury. If anything, getting a PA drivers
license now is yet another attempt to obstruct justice.
As I have said before, I don’t get intimidated by either Obama or by Berg. One cannot file a fraudulent and
malicious legal action against me and expect to shut me up and make me stop reporting on illegal and criminalactivity. All that these people are doing, is adding counts of fraud, perjury and obstruction of justice. The
only thing Berg can do, is come clean, disassociate himself from Lisa Liberi, who has a record of forgery and
he needs to hire a forensic document examiner to check all the records handled by Lisa Liberi. We cannot
win in court with forged records. This information was already on the blogs before I got it and it will be on the
blogs, his continuing denial of clear evidence has no merit and undermines everybody in the resistance
movement, everybody who wants to get to the truth. The only way to win, is by clean evidence, unsealing the
vital records and letting the Supreme Court decide the issue of the Natural Born Citizen.
> From: [email protected]
> To: [email protected]
> Subject: RE: HELLO ??? (again)> Date: Sun, 15 Mar 2009 17:02:00 -0700
>
> Indeed it would. If you would pass this on to Dr.O, I will go out to San Bdo
> this week and have a look at the 2002 file, dontcha think?
> N
>
> —–Original Message—–
> From: Lisa Ostella [mailto:[email protected]]
> Sent: Sunday, March 15, 2009 4:49 PM
> To: Neil Sanky
> Subject: RE: HELLO ??? (again)>
> Hmm, if the forged documents actually came out of Phil Berg’s office, well,
> filing lawsuits would be an excellent cover, huh?
>
> Factcheck is in Pennsylvania.
>
> As is Phil Berg.
>
>
> Lisa Ostella
rying to stay away from Liberi-Berg issue, but i got more questions a... http://www.orlytaitzesq.com
5/1/2011 1
Exhibit "47"
Pg. 427
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 27 of 29 Page ID#:4886
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1908-plaintiffs-exhibits-45-47-to-amended-complaint1908 28/29
> Defend Our Freedoms Foundation
> http://defendourfreedoms.org <http://defendourfreedoms.org/>
> Peace through Strength
> http://www.barofintegrity.com <http://www.barofintegrity.com/>
>
>
>
>
>>
>
>
> > From: [email protected]
> > To: [email protected]
> > Subject: RE: HELLO ??? (again)
> > Date: Sun, 15 Mar 2009 16:35:46 -0700
> >
> > Yes but a SEAL !!, and HOW MANY aliases?
> >
> > —–Original Message—– > > From: Lisa Ostella [mailto:[email protected]]
> > Sent: Sunday, March 15, 2009 3:46 PM
> > To: Neil Sanky
> > Subject: RE: HELLO ??? (again)
> >
> > Insight, such as, Lisa Liberi (Phil Berg’s assistant) really being Lisa
> > Richards, with a police record for ID theft?
> >
> > Mighty convenient talent to have when there are multiple identities flying
> > around.
> >
> > I’ve not researched that insight yet. I didn’t have a warm and fuzzy
> > interaction with (redacted name of volunteer )So I don’t know if this is planted info droppings
> > or not.
> >
> >
> > Lisa Ostella
> > Defend Our Freedoms Foundation
> > http://defendourfreedoms.org <http://defendourfreedoms.org/>
> > Peace through Strength
> > http://www.barofintegrity.com <http://www.barofintegrity.com/>
> >
Category: Uncategorized
Comments
7 Responses to “I am trying to stay away from Liberi-Berg issue, but i got more questions and here is more
info.”
Wahoo1.
rying to stay away from Liberi-Berg issue, but i got more questions a... http://www.orlytaitzesq.com
5/1/2011 1
Exhibit "47"
Pg. 428
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 28 of 29 Page ID#:4887
8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.8 - Plaintiffs Exhibits 45-47 to Amended Complaint.190.8
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1908-plaintiffs-exhibits-45-47-to-amended-complaint1908 29/29
May 31st, 2009 @ 8:18 pm
WOW! What is going on?
I am totally confused! I have been a way for a while, so I don’t know what I have missed. Are you
saying Lisa who works for Phil Berg has forged documents that he has used? OMG This whole thing is
crazy, why !?!?!?!?!
May 31st, 2009 @ 8:20 pm
I don’t know if she forged the documents that he presented, but she has an extensive police record of
forgery of documents and she was convicted here in CA last year
2.
Phoebe
May 31st, 2009 @ 9:57 pm
Is california a community property state? Does that mean Yosef’s assets are in jeopardy as well?
3.
sillyhaha
June 1st, 2009 @ 2:46 am
Is it possible that Lisa L forged the Indonesian school record and the two affidavits from the African
ministers?
Could Lisa L and Berg just be scamming people for Pay Pal money?
I donated to Berg 5 months ago, before I knew anything about Lisa L. I may have to ask for a refund.
4.
Linda Starr
June 5th, 2009 @ 11:59 am
There is ample evidence that plaintiff’s have each made false sworn affidavits to one or more courts.The truth is an absolute affirmative defense to false allegations of defamation.
Just yesterday I posted a comparison of statements in two cited cases on my blog , one where this PA
attorney was sued for malpractice and in another where he claimed he did not have any grievance
against him. Funny how he left out the malpractice suit for negligence because he defaulted on filing a
timely answer in a related case.
Yet somehow, I am supposed to be the one damaging their so-called great “professional” reputations!
As a result of their false assumptions, we are sued for defamation for allegedly speaking the truth! This
claim of their reputations being damaged by defamation is the grossest lie of them all! By their own
actions they destroyed their reputations all on their own. There isn’t any place where I publicly postedany confidential information.
I trusted these people and was not only deceived, but have been grossly defamed and betrayed. These
people don’t know what the words friend, loyalty, or honor means; much less understand the concepts
of truth and/or attorney client privilege. And I’m not even talking about myself here. This lawyer is
going to find out the hard way, in court, that his assistant has a big mouth!
And for the record and everyone’s edification, five minutes after the deadline passed for respondent’s
h h i i hi l hi i h d d f l d f d
5.
rying to stay away from Liberi-Berg issue, but i got more questions a... http://www.orlytaitzesq.com
Case 8:11-cv-00485-AG -AJW Document 190-8 Filed 05/20/11 Page 29 of 29 Page ID#:4888